November 8, 2024 Thomas James Segrave, Jr. Chief Executive Officer flyExclusive, Inc. 2860 Jetport Road Kinston, NC 28504 Re: flyExclusive, Inc. Registration Statement on Form S-1 Filed October 28, 2024 File No. 333-282855 Dear Thomas James Segrave Jr.: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Cheryl Brown at 202-551-3905 with any questions. Sincerely, Division of Corporation Finance Office of Energy & Transportation cc: Donald R. Reynolds, Esq.